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AfOR and REAL jointly respond to the EA consultation on the redrafted AD Quality Protocol

The Environment Agency has invited comments on proposals for revision of the Anaerobic Digestion Quality Protocol.  Below, AfORhas reproduced the EA's invitation.
 
The joint AfOR and REAL's comments to the redrafted AD Quality Protocol can be downloaded HERE.
 
"As you know, Keith Froud has been leading our review for some months alongside WRAP’s evaluation of PAS 110.  As indicated at the workshops that we have held, the proposed changes have led to a revised document that is similar to the existing Quality Protocol in most respects, and whose fundamental principles remain the same.
 
The main changes in the revised document are:
  1. redrafting to provide greater clarity,
  2. revisions to appendix B (acceptable inputs) - clarification of acceptable inputs and associated codes,
  3. including additional codes to describe waste that is subject to certain forms of pre-treatment at facilities between the site of waste production and the AD facility; and
  4. the removal of the requirement for land managers using digestate to maintain records for the specific purposes of the Quality Protocol.
 
 
Additional inputs

During the review we have invited suggestions for additional waste types backed up with supporting evidence for why they should be included.  We have not received any evidence supported proposals through the review process. As a result we are consulting on the potential changes that have been put forwards over the last  two years of operation on the Quality Protocol only.
 

Inputs that we intend to remove

We are proposing that some wastes currently listed as acceptable inputs are removed from the Quality Protocol, for the reasons set out below.

Plastics
The current Quality Protocol allows waste plastics and plastic packaging, with the requirement that they comply with BSEN13242 or similar standards.  Although BS EN 13242 covers digestion of material that can then be used to produce (aerobic) compost, it is a standard for compost and not digestate.  It is not therefore an appropriate standard for the AD Quality Protocol and we are unaware of any similar standards that apply to digestate.
 
We know that compostable plastics do not break down fully under anaerobic conditions, with implications for digestate quality.  We also know that they can cause operational difficulties in AD facilities.  Standard practice is that packaging of this sort is removed before materials enter the digestion process.  We therefore propose that waste plastics are removed from appendix B although we recognise that incidental quantities of such material may enter the digestion process in practice.  This does not mean that food waste should not be collected in BS14342 compliant material.   Our intention is to restrict the intentional input of plastics into AD.

Tanning liquor and sludges from leather production (coded as 04 01 05 and 04 01 07)
The current Quality Protocol lists these wastes as acceptable on the condition that they are free from chromium.  We are unaware of this waste currently being used as an input, and in any case our view is that it may be difficult for operators to ensure that the sludge is free from chromium, with implications for digestate quality.  We therefore propose that these wastes are removed from the Quality Protocol.
 
Residues from commercial mushroom cultivation
We do not consider that this waste (‘mushroom compost’) is beneficial to the AD process and therefore propose to remove it from the input list.

Further information requested - wastes from pulp, paper and cardboard production and processing
We are seeking views on which wastes from pulp, paper and cardboard production and processing are appropriate for inclusion. See below for further detail.
 
End-uses
 
During the review we have also invited suggestions for additional end-uses for digestate that could be added to the Quality Protocol.  Some additional end-uses have been proposed e.g. as an additive in growing media, as a fertiliser other than for soil/field grown-agriculture and horticulture.  At present, there is insufficient evidence of the suitability and marketability of digestate in these applications, which would be required to meet the end-of-waste test required for inclusion in the Quality Protocol.  WRAP is supporting trials to assess the viability of a number of additional uses and these may be considered for inclusion when the Quality Protocol is reviewed again.
 

Review of PAS110
WRAP’s evaluation of PAS 110 is ongoing but we do not consider it necessary to delay consultation on the Quality Protocol any further.
 
 
End-of-waste legislation on biowaste

We are continuing to  ensure that the existing UK position is taken into account by the European Commission in the work that it is undertaking to derive EU end-of-waste legislation on biowaste. However, given the uncertainties around this process we consider it essential to ensure that the Quality Protocol remains fully relevant, and intend to continue with the review and now consult on proposals to update the Quality Protocol.
 

Your input

Two versions of the revised Quality Protocol are downloadable from this webpage: a ‘clean’ version with new or revised text highlighted in yellow; and a ‘track changes’ version so you can see in full how the revised document differs to the existing one.

Comments or drafting suggestions on the revised document are welcomed as too are views on topics 1 and 2 below.
 
1. Should any biodegradable plastics and similar ‘biodegradable’ materials be included in appendix B? If so, please identify:
 
    a)  which types of waste;
    b)  why they should be included; and
    c)  what standard or specification should be adhered to, with supporting evidence, to ensure inappropriate materials are kept out of the digestion process and resulting digestate.

2. We are seeking views on which wastes from pulp, paper and cardboard production and processing are appropriate for inclusion. Options include either or both of the following:
 
    a) 03 03 10 fibre rejects, fibre-, filler- and coating-sludges from mechanical separation; and/or
    b) 03 03 11 sludges from on-site effluent treatment other than those mentioned in 03 03 10.

    We invite views on the suitability of each of these materials for AD, considering;
 
    (i) their potential contribution to the process,
    (ii) their potential impact on digestate quality, and
    (iii) the level of interest from AD operators in processing them. 
 
    We do not intend to include de-inking sludges or wastes that contain or have been mixed with de-inking sludges.

 
Next steps

The revised Quality Protocol will be updated after this consultation.  We will then evaluate whether the new document can be published without further delay or whether it is necessary for it to be subject to European notification – a process that can take 3 to 6 months – before it can be published."

Please click
HERE to download the template for making responses.  
- HERE to download the redrafted AD Quality Protocol (tracked changes version).
- HERE to download the redrafted AD Quality Protocol ('clean' version).
 
The EA adds that: "All responses will be analysed and considered, but it may not be possible to respond in all cases."
 
The Environment Agency's deadline is 18th October 2012, so to give AfOR sufficient time to compile member responses, please email your response to kiara@organics-recycling.org.uk  by 5:30 pm on Tuesday 9th October.  Call Kiara on 07717294793 if you wish to discuss the proposed changes.
 
Webpage published: 23rd August 2012.
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